Telecom Italia

Composition and characteristics of the administrative and supervisory bodies

Reference: page 120 (Corporate Governance).

The Board of Directors of TIM S.p.A., appointed by the Shareholders' Meeting of April 23, 2024 for 2024-2026, is composed of nine Directors: one Executive Director (CEO Pietro Labriola, also General Manager) and eight non-executive Directors, including Chairwoman Alberta Figari. Six directors (67%) are qualified as independent under Art. 148 of the Consolidated Law on Finance. Female representation on the Board is 44% (four of nine Directors), consistent with the Articles of Association' two-fifths threshold.

ESG competence: concentrated in five Directors (Figari, Gorno Tempini, Labriola, Perrazzelli, Siragusa), covering governance of sustainability committees, ESG integration into strategy, ESG regulation, environmental impact assessment, and digital transformation for sustainability.

Board committees: Control and Risk Committee; Nomination and Remuneration Committee; Related Parties Committee; and the Sustainability Committee (established April 2021, chaired by the Chairwoman, including the CEO since May 2024), which oversees ESG issues and interacts with the Control and Risk Committee on the double materiality analysis and Sustainability Reporting.

Information flows on sustainability matters

Reference: page 123-124 (Governance).

The Board of Directors is periodically informed on material ESG impacts, risks and opportunities and related policies, via the Control and Risk Committee and the Sustainability Committee, which operate on an annually defined agenda. The Board of Statutory Auditors is also involved, with access to all documentation.

The outcome of the double materiality analysis is presented annually by the Corporate Communication & Sustainability Department in joint session to the Control and Risk Committee, the Sustainability Committee and the Board of Statutory Auditors, then submitted to the Board of Directors. In 2025, the DMA outcome was presented in joint session on November 3, 2025 and submitted to the Board of Directors on December 11, 2025.

Sustainability issues are integrated into the Enterprise Risk Management (ERM) process, which identifies, quantifies and monitors significant risks including ESG risks, with periodic reporting to the Control and Risk Committee and Board of Directors on risk Tolerances and mitigation plans.

Integration of sustainability performance in incentive schemes

Reference: page 124 (Governance).

The Remuneration Policy, approved by the Shareholders' Meeting on June 24, 2025, balances economic-financial, stock performance and ESG parameters.

Short-term incentive (2025): ESG objectives carry a total weight of 22%, split into: Environment – number of Data Centers certified under the European Taxonomy (Italy); Social – percentage of female hires out of total hires (Group); Governance – percentage of detractors in Q4 2025 (Domestic BU).

Long-term incentive – 2025-2027 Performance Share Plan (CEO, top management, key managers): two economic-financial indicators (EBITDA-CapEx 50%, Total Shareholder Return 20%) plus two ESG indicators totalling 30%: eco-efficiency of the mobile network (15%, Domestic BU) and percentage of women in formalized positions of responsibility (15%, Domestic BU). Climate issues are integrated via the Environment objective (15% weight) of the LTI Plan, applied to the CEO and Managers with Strategic Responsibilities.

Statement on due diligence

Reference: page 125 (Governance).

TIM's due diligence is structured in five phases, each mapped to specific disclosure requirements:

• Embedding in governance, strategy and business model: GOV-2, GOV-3, SBM-3 (incl. E1-S1-S2-S3-S4)
• Stakeholder engagement: ESRS 2 MDR-P, GOV-2, SBM-2, IRO-1 (incl. E1-S1-S2-S3-S4)
• Identification and assessment of impacts and risks: IRO-1, SBM-3 (incl. E1-S1-S2-S3-S4)
• Prevention, mitigation and remedy: ESRS 2 MDR-A, E1-3, E5-2, S1-4, S2-4, S3-4, S4-4
• Monitoring and communication of effectiveness: MDR-T

These processes identify, assess and manage TIM's actual and potential negative impacts on people and the environment, and the related sustainability risks and opportunities, across the Group's activities and value chain, and are used to define prevention, mitigation and remedy actions with effectiveness monitored over time.

Internal Control System on Sustainability Reporting (SCIRS)

Reference: page 126 (Governance).

TIM appointed a Sustainability Reporting Manager (Maria Enrica Danese, Head of Corporate Communication & Sustainability, appointed Dec 11, 2024, confirmed Nov 11, 2025) who, with the CEO, certifies the accuracy, reliability and compliance of the Sustainability Reporting.

In 2024 TIM introduced the SCIRS (Internal Control System on Sustainability Reporting), inspired by the COSO framework and the 2023 "Achieving Effective Internal Control of Sustainability Reporting" guide, structured around 17 principles across 5 components (Control Environment, Risk Assessment, Control Activities, Information System, Monitoring).

Phases: scope definition by risk/relevance; Entity Level Controls; IT General Controls; Process Level Controls; management testing and sign-off; independent audits by the Compliance Department; deficiency assessment and remediation plans; final certification to the Administrative and Supervisory Bodies. Prioritization drivers include data/calculation complexity, reputational impact, centrality to sustainability targets, rating-agency materiality, and DMA priority.

Business model and value generation

Reference: page 127 (Strategy).

TIM Group is the main integrated telecommunications and digital infrastructure operator in Italy, developing fixed/mobile networks, data centers and digital solutions; Sparkle operates a global optical fiber network (classified as Discontinued Operations, IFRS 5, pending disposal); TIM S.A. leads 4G/5G in Brazil.

Workforce: 26,177 employees at Dec 31, 2025 (Italy 17,231; Brazil 8,702).

Benefit Corporations within the Group: Noovle (Cloud/Edge, since July 2021), Olivetti (IoT/Big Data, since January 2023), Mindicity (smart cities, acquired by Olivetti 2022).

2025 ESG results vs. 2025-2027 Plan targets: 100% electricity from renewable sources (Italy target met; Scope 2 market-based emissions at zero); women in leadership positions 33.5% (2025 target 35.5%); female hires 52.8% (target 50% by 2027, already exceeded); IoT/Cloud/Security revenue +22% YoY (target +17%); digital-identity services (PEC/SPID/Digital Signature) +34% vs. 2023 baseline (target +30%); TIM S.A. AI training reached 60% of employees (target 90% by 2027).

Stakeholder engagement

Reference: page 130 (Strategy), following AA1000APS/AA1000SES guidelines.

Eight stakeholder categories: TIM people (incl. trade unions); Customers; Suppliers; Business community (peers, OTTs, associations); Bodies and institutions; Financial community; Civil society; Media.

Selected 2025 engagement metrics: Domestic intranet ~20 million visits; customer listening ~3.2 million interviews in Italy; 299 new suppliers qualified (35% ESG-assessed); 4 JAC on-site supplier audits; ~7 million visits to the TIM Group website; ~175 press releases issued.

Process: integration into governance/strategy, stakeholder identification and prioritization, engagement planning, diversified tools (meetings, surveys, focus groups), documentation, monitoring/evaluation, and reporting through the Sustainability Reporting.

The DMA outcome, incorporating stakeholder input, was presented to the Control and Risk Committee, Sustainability Committee and Board of Statutory Auditors on November 3, 2025 and to the Board of Directors on December 11, 2025. No critical issues requiring remedial measures emerged at the reporting date.

Material impacts, risks and opportunities

Reference: page 131-136 (Strategy).

TIM's 2025 double materiality analysis identified 38 material IROs: 10 negative impacts, 6 positive impacts, 12 risks and 10 opportunities, tracing back to 7 ESRS topics: E1 (Climate change), E5 (Resource use and circular economy), S1 (Own workforce), S2 (Workers in the value chain), S3 (Affected communities), S4 (Consumers and end-users) and G1 (Business conduct). E2, E3 and E4 were explicitly excluded as not material.

Selected material IROs: growth of 5G/data centers increasing energy consumption and emissions (IRO 7, E1); GHG emissions across the value chain (IRO 18, E1); vulnerabilities in computer systems risking data privacy (IRO 1, S1/S4); inadequate e-waste management (IRO 37, E5); lack of digital-inclusion action risking social exclusion (IRO 12, S4); human rights violations along the supply chain (IRO 38, S1/S2); anti-corruption/compliance failure risk (IRO 2, G1); geopolitical/health-crisis supply disruption (IRO 34, S4/G1).

TIM has not identified material anticipated financial effects on financial position from these IROs expected within the next annual reporting period beyond what is disclosed under E1/E5 current-and-potential financial effects (page 135).

Double materiality analysis process

Reference: page 136-139 (Strategy).

TIM's 2025 DMA followed the CSRD and EFRAG's Implementation Guidance 1, covering TIM S.p.A., TIM S.A., Noovle, Olivetti, Telecom Italia Sparkle and Telsy. A dynamic semantic engine analyzed public sources (regulations, peer reports, news) to build a first list of IROs, integrated with Enterprise Risk Management (ERM) benchmarking. The list was tested against materiality thresholds and validated through individual interviews with internal stakeholders (Sustainability Committee directors, Chairwoman, C-level, function managers) and a structured survey of external stakeholders across 8 categories, involving over 5,000 stakeholders (34% response rate).

Scoring: impacts scored 1-25 (severity × probability); threshold of 9+ deemed material. Risks/opportunities scored 1-25 (magnitude × probability), threshold 9+, with human-rights risks treated as material regardless of score. Results were calibrated with the ERM function and validated by the Sustainability Committee, Control and Risk Committee and Board of Directors.

Climate-specific process (E1 IRO-1): NGFS scenarios RCP 2.6/4.5 and CLIMADA quantify physical risk (heat stress: €16-50m estimated productivity loss at +1.4°C to +2°C) and a carbon-tax transition scenario (€83.5/tCO2) under a Net Zero-by-2040 pathway.

ESRS disclosure requirements covered

Reference: page 150-153 (ESRS Table of Contents).

TIM's 2025 sustainability statement covers: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2); ESRS E1 Climate change (E1-1 to E1-7 reported; E1-8 not applicable as TIM does not set an internal carbon price; E1-9 phase-in); ESRS E5 Resource use and circular economy (E5-1 to E5-3, E5-5 reported; E5-4 "not material obligation"; E5-6 phase-in); ESRS S1 Own workforce (S1-1 to S1-6, S1-8 to S1-10, S1-12 to S1-17 reported; S1-7 and S1-11 phase-in); ESRS S2 Workers in the value chain (S2-1, S2-4, S2-5 reported; S2-2, S2-3 phase-in); ESRS S3 Affected communities (S3-1, S3-4, S3-5 reported; S3-2 phase-in); ESRS S4 Consumers and end-users (S4-1 to S4-5, all reported); ESRS G1 Business conduct (G1-1 to G1-4, G1-6 reported; G1-5 "not material obligation").

Topics explicitly excluded as not material: "ESRS E2 – Pollution", "ESRS E3 – Marine Waters and Resources" and "ESRS E4 – Biodiversity and Ecosystems" (direct quote, p.150).

Climate resilience analysis and transition plan status

Reference: page 178-179 (Climate Change).

TIM's prior climate targets are being updated alongside the new 2026-2028 Business Plan; the new transition plan and targets will be formalized and communicated during 2026, using 2024 as baseline year following a 2025 methodological expansion of Scope 3 categories.

Resilience analysis: conducted cyclically within the ERM system using the CLIMADA quantitative model and NGFS scenarios (RCP 2.6, RCP 4.5), covering acute physical risks (floods, landslides, fires, wind storms) across TIM S.p.A., TIM S.A. and Telecom Italia Sparkle assets. For hydrogeological risk under a Net Zero-by-2050 transition scenario, TIM used Climada-based risk maps to correlate assets to climate-risk levels through 2030. Chronic heat-stress risk is estimated at €16m (best case, +1.4°C, -0.8% labour productivity) to €50m (worst case, +2°C, -2.4% productivity).

Strategic responses: resilient connectivity infrastructure, cloud/smart-working/telemedicine solutions, ESG criteria in procurement, energy-efficiency R&D, and periodic review of the operating model against the evolving climate scenario during Strategic Plan definition. TIM is not classified among ESRS high-climate-impact sectors at Group level (Olivetti and TIM Retail are, at entity level).

Policies related to climate change

Reference: page 180 (Climate Change).

The material IROs related to ESRS E1 are seven (IROs 7, 9, 13, 18, 21, 23 and 31), overseen through the "Commitment to Environmental Sustainability in the TIM Group" policy, the "Purchases of Products and Services" policy, and the "TIM Group Code of Ethics and Conduct".

Commitment to Environmental Sustainability policy commits TIM to: mitigation (long-term emission-reduction targets in the Business Plan, supplier selection on environmental criteria); adaptation (operational continuity measures against extreme weather); energy efficiency; and spread of renewable energy.

Purchases of Products and Services policy integrates climate criteria into procurement: ESG criteria from qualification through Vendor Rating (mitigation); supply-risk oversight for continuity (adaptation); and purchasing choices favoring energy efficiency/renewables.

TIM S.A. additionally applies its own "Climate change management" policy covering adaptation, mitigation, energy efficiency and renewable sourcing in Brazil, consistent with regulatory requirements and Group guidelines.

Actions and resources for climate change

Reference: page 180-184 (Climate Change).

Five action areas: (1) renewable energy use; (2) reduction of energy/fossil-fuel consumption; (3) low-emission transport; (4) supply-chain decarbonization; (5) additional mitigation initiatives.

Renewables: 100% of Domestic BU electricity from renewables in 2025 (91.91% Guarantees of Origin, 8.09% PPA); Brazil 38% via I-REC plus 62% from TIM S.A.'s own 134 renewable plants (120 PV, 12 small-hydro, 2 biomass).

Data centers: 16 in Italy (7 Core, 6 Public Cloud, 3 micro), 37 in Brazil; cogeneration (7.76 GWh self-consumed), waste-heat recovery at Rozzano (5.75 GWh to district heating); 11 data centers certified under the EU Code of Conduct on energy efficiency; average PUE 1.608 (Italy), 1.58 (Brazil, -4% YoY).

Network: 5G traffic reached 16% of total mobile traffic (efficiency +0.41 W/bit); TIM S.A. RAN-sharing with Vivo closed 3,933 redundant sites.

Fleet: 51% of the 1,978-vehicle mixed-use fleet is low-emission (+7pp YoY); 18% of the 79-vehicle car-sharing fleet is full-electric.

Financing: €499m residual 2021 Sustainability Bond (Italy); BRL 1.6bn 2021 Sustainability-Linked Bond (TIM S.A.). Total identifiable E1-3 spend: Domestic BU €39.1m OpEx / €235.9m CapEx gross of taxonomy; TIM S.A. €154.7m OpEx / €17.1m CapEx.

Targets related to climate change

Reference: page 185 (Climate Change).

TIM's previously adopted climate targets are being updated as part of the new Business Plan and transition plan; new targets will be formalized and communicated during 2026. In the transitional period, TIM continues to monitor emissions performance (Scope 1/2/3, emission intensity, total energy consumption and renewable share, and data-center energy-efficiency indicators) against the trajectory of prior reduction actions.

For 2025 outturns against the prior Plan's ESG targets (e.g., 100% renewable electricity procurement achieved in Italy in 2025, consistent with Brazil since 2021), see disclosure ESRS 2 SBM-1 "Strategy, business model and value chain".

Energy consumption and mix

Reference: page 186 (Climate Change), TIM Group environmental perimeter, 2025 vs. 2024 (restated).

Total consumption was essentially flat (-0.4%), but the mix shifted sharply: fossil consumption fell 74%, offset by full coverage of purchased electricity through Guarantees of Origin, I-RECs and PPAs, lifting the renewable share by 12 percentage points to 95.84%.

High-climate-impact entities (Olivetti, TIM Retail) reported separately: total consumption 5,270.29 MWh (2025) vs. 4,277.93 MWh (2024, +23%, mainly TIM Retail vehicle fuel now captured); energy intensity 23.23 MWh/€m revenue (+24.5% YoY).

Gross Scope 1, 2, 3 and total GHG emissions

Reference: page 188-193 (Climate Change), GHG Protocol Corporate Standard, TIM Group environmental perimeter.

Total emissions fell ~4% YoY (market-based). Scope 3 represents 99% of the total (vs. 93% in 2024); Scope 2 market-based reached zero following full renewable-electricity coverage; Scope 1 fell 36% (reduced trigeneration operation, boundary changes with FiberCop, less refrigerant loss). Scope 3 rose 1.5%, driven by Category 1 (Purchased goods, +3.8%) and Category 2 (Capital goods, +2.2%), partly offset by Category 11 (Use of sold products, -17.4%). GHG intensity: 154.72 tCO2eq/€m revenue market-based (-5.4% YoY). TIM S.A. represents 27% of Group Scope 1+2+3 emissions (down from 29% in 2024).

GHG removals and carbon credits

Reference: page 194 (Climate Change).

TIM does not carry out its own GHG removal/storage activities; neutralization is achieved solely through purchased certified carbon credits.

Domestic BU: 505 tCO2eq generated from visits to 21 main commercial/institutional websites in 2025 were offset via 505 carbon credits from "The Envira Amazonia Project" (Brazil, avoided-deforestation forest conservation), certified to the VCS (Verra) standard with CCBS Triple Gold Level Distinction; credits verified via the CO2web® methodology (Rete Clima, ICMQ-certified) and not generated within the EU.

TIM S.A.: neutralizes direct (Scope 1) GHG emissions through certified carbon credits; 13,418 credits purchased in 2025, selected using recognized certification criteria and community/environmental co-benefit potential.

Internal carbon pricing

Reference: ESRS Content Index, p.153 (Climate Change).

The ESRS content index states directly, against Disclosure Requirement E1-8: "The Group does not set an internal carbon price" (no page reference given, i.e. not disclosed in the narrative sections).

For context, TIM's IRO-1 process for climate (page 138) does use a carbon-tax scenario assumption for transition-risk analysis only — €83.5 per tonne CO2 (2024 average price) — to estimate potential future operating-cost exposure under an assumed regulatory carbon tax. This is a scenario-planning input for risk assessment, not an internal carbon price applied to day-to-day investment or business-case decisions, which TIM confirms it does not operate.

Policies related to resource use and circular economy

Reference: page 195 (Resource use and circular economy); ESRS Content Index note: "two material IROs were identified, both attributable to the ESRS E5 topic" (IRO 28, opportunity, and IRO 37, negative impact).

Governed by the "Commitment to Environmental Sustainability in the TIM Group" policy and the "Waste management" procedure. The environmental sustainability policy commits TIM to circular material flows, reduced reliance on virgin raw materials, and Zero Waste to Landfill objectives; the waste procedure governs the full waste lifecycle from classification to transfer to authorized parties, prioritizing prevention, reuse and recycling in line with circular-economy principles, and covers TIM S.p.A. and Telecom Italia Sparkle with reference application across other Domestic Group companies.

Actions related to resource use and circular economy

Reference: page 195-197 (Resource use and circular economy).

Waste/water: Brazil "Take Back" WEEE program recovered 67 tonnes in 2025 (98% recycling rate); Noovle Data Center water monitoring improved WUE to 0.097 l/kWh (from 0.291 in 2024) across 11 centers; rainwater reuse at 3 data centers recovered ~480 m3.

Device reuse: "TIM Rivaluta Smartphone" trade-in collected 21,787 smartphones (+~300% YoY, ~80% regenerated, ~45 tonnes e-waste avoided); Brazil's "TIM Troca Smart" collected 15,933 devices (99% reused); "All Risk Assistance" replaced ~12,000 devices with regenerated units (75% of replacements); Turin Prison partnership regenerated ~38,000 modems.

E-SIM: ~270,000 new e-SIMs activated in 2025 (98% lower carbon footprint per unit vs. physical SIM; ~34 tCO2eq avoided).

Contributes to mitigating negative impact IRO 37 (waste) and opportunity IRO 28 (material recovery). Total identifiable spend: Domestic BU €9.9m OpEx/€3.9m CapEx gross of taxonomy; TIM S.A. €2.7m OpEx/€0.09m CapEx.

Targets related to resource use and circular economy

Reference: page 198 (Resource use and circular economy).

TIM monitors circular-economy KPIs including: number of devices recovered/regenerated via trade-in and reuse-preparation programs; percentage of modems marketed with carbon-footprint (EPD) certification; recycled-material content in TIM-branded products; quantity of precious materials recovered from WEEE; total waste produced; waste diverted from disposal (by weight); and waste directed to disposal by treatment type.

TIM S.A. specific target: reuse/recycling rate of solid waste, with a reference level of 96% by 2026. Monitoring is supported Group-wide by ISO 14001 certification (100% of reporting manufacturing sites in 2024/2025).

Resource outflows

Reference: page 199 (Resource use and circular economy).

TIM-branded modems (~90% of branded products) are designed for ~10-year durability, with a required Mean Time Between Failure of 300,000+ hours, recyclable/recycled material content, and 100% recycled/recyclable cardboard packaging. In 2025, TIM shipped over 1 million modems, 70% with EPD (Environmental Product Declaration) certification — up from the first EPD modem (TIM Hub Pro) introduced in 2024, joined by TIM Hub+ XDSL in 2025.

The product-recyclability decline reflects the mix shift toward TIM HUB+ XDSL (lower-recyclability ADSL filter component); packaging recyclability improved from broader adoption of lower-plastic packaging.

Waste

Reference: page 199 (Resource use and circular economy: Waste production and treatment).

Waste classified per the European Waste Catalogue (Domestic, per Directive 2008/98/EC as amended) and ISO 14001 (Brazil). Main streams: mixed packaging, WEEE, cables/metals (non-hazardous); batteries/accumulators (hazardous).

Total waste generated fell 24.8% YoY; 96.7% of 2025 waste was diverted from disposal (preparation for reuse, recycling, other recovery).

Policies related to own workforce

Reference: page 201-202 (Own workforce).

The double materiality analysis identified twelve material IROs (1, 5, 15, 17, 20, 22, 24, 26, 30, 35, 36 and 38) related to "Own workforce." These are monitored through the Code of Ethics and Conduct, Human Rights Policy, Human Resources and Equal Opportunities Policy, Management of Gender-Based/Sexual Harassment and Bullying Policy, Whistleblowing Procedure, Report on the Remuneration Policy, Health and Safety Policy, Personal Data Protection Framework, and Information Security Policy.

TIM S.A. additionally applies its own Code of Ethics, Human Rights Policy, Social Responsibility Policy, Diversity and Inclusion policy, Occupational Health and Safety policy, and Business Development and Learning policy in Brazil, covering forced/child labor prevention, discrimination and vulnerable-group protection.

Engaging with own workforce

Reference: page 202-203 (Own workforce).

Direct engagement (Domestic 2025): DMA employee survey — 531 employees sampled, 44.2% participation; "InAscolto" annual welfare survey — satisfaction 3.4/5; Climate Survey — engagement level 56%, analyzed pseudo-anonymized by independent parties and shared with the Board.

Brazil: Pulse surveys plus an annual Climate and Engagement Survey covering culture of integrity, agility, leadership, well-being; results monitored by the People, Culture & Organization function.

Indirect engagement: Industrial Relations Protocol redefined in 2025; over 25 meetings held with parent-company trade union representatives during the year on bargaining, organizational change, training and employment safeguards. Brazil's 2025-2026 collective contract includes AI-ethics clauses, environmental-sustainability provisions, reduced 6x1 call-center hours, and a mental-health/well-being program.

Remediation channels for own workforce

Reference: page 203-205 (Own workforce).

Whistleblowing Channel: aligned with EU Directive 2019/1937; dedicated portal (with Unique Identification Code for anonymous tracking), toll-free voicemail (800 664 411), and postal channel to the Supervisory Body; managed by the Audits Department with anti-retaliation protections. Brazil operates a parallel 24/7 multichannel Whistleblower Channel via the Internal Audits function.

Health & Safety channels: HSE Portal for hazard reports; Workers' Safety Representative consultation; direct supervisor reporting. Brazil provides an anonymous accident-reporting channel plus a social worker/psychologist support program.

Cybersecurity/physical security channels: dedicated intranet mailboxes, Abuse Desk, and a 24/7 Security Operations Center (SOC) and Security Control Room. These channels address material IROs 1 (privacy), 15 (H&S), 17 (incentive misalignment) and 36 (right to disconnect).

Actions on material impacts on own workforce

Reference: page 205-213 (Own workforce).

Working conditions: National Telecom CBA renewal protecting purchasing power (mitigates IRO 17); agile-work agreement (3 days remote/2 on-site from July 2025, >96% adoption) with disconnection-protection practices addressing IRO 36; parenting support (#BParent Plan, Pacchetto Bebè, TIM CARE — 557 platform accesses); H&S management per Legislative Decree 81/08, ISO 45001, 39,349 training hours in 2025 (mitigates IRO 15); Industrial Relations Protocol signed February 2025 (addresses IRO 38).

Equal treatment: Advanced-training programs for under-35s (615 participants); PlayMaker managerial AI/change-management training (~850 executives/managers); Age Empowerment intergenerational mentoring (82 colleagues); Fluent Future language coaching (300 colleagues, 12,000 hours).

Total identifiable 2025 spend spans work-life balance (Domestic €789k OpEx; TIM S.A. €76k), and H&S (Domestic €508k OpEx/€15k CapEx; TIM S.A. €24.6m OpEx/€6.9m CapEx).

Targets related to own workforce

Reference: page 213-214 (Own workforce).

TIM monitors training participation/hours by gender and category, salary adequacy against contractual minimums, welfare adherence, workforce composition (gender/age/grade), women in leadership, female-hire share, pay-gap trend, flexible-working adoption, family-leave uptake, and well-being service access; and, in cybersecurity/privacy, incident counts, response times and training coverage; and, on human rights, whistleblowing report volumes and resolution times.

In Italy, monitoring is supported by the Steering Committee for Gender Equality and UNI/PdR 125:2022 gender-equality certification (since 2023). TIM S.A. targets 90% of employees trained in digital-skills programs. Results against the prior Plan's workforce targets are reported under ESRS 2 SBM-1.

Workforce characteristics

Reference: page 215 (Own workforce), TIM Group, Dec 31, 2025 vs. 2024.

Total headcount fell 2.4% YoY; gender composition remained balanced (~50/50); turnover rose 1.79pp, influenced by higher labor-market mobility in Brazil.

Collective bargaining coverage and social dialogue

Reference: page 216 (Own workforce).

100% of Group employees are covered by collective bargaining agreements. In Italy, coverage is split across the CCNL TLC (telecommunications employees, 15,474 covered), the Tertiary/Distribution/Services CCNL (983 employees), and executive-level CCNLs (268 + 1 executives).

Employee representation (EEA): 96.14% of employees covered by worker representatives in 2025 (down from 98.04% in 2024, due to non-reconstitution of one Company Union Representation/RSA). No European Works Council or equivalent transnational body has been established.

Brazil's 2025-2026 collective contract was approved across all States and the Federal District following union-federation negotiations, including AI-ethics and environmental-sustainability clauses.

Diversity metrics

Reference: page 217-219 (Own workforce), TIM Group.

Senior management gender distribution: 19 people in 2025 (up from 17 in 2024); women 21.05% (4 of 19, up from 17.65%/3 of 17).

Age distribution (2025): under 30 – 7.30% (1,911 employees); 30-50 – 46.54% (12,184); over 50 – 46.16% (12,082). The over-50 share rose from 42.91% in 2024 as the 30-50 cohort shrank, reflecting an ageing workforce profile (company average age above 50, per the CEO's shareholder letter).

"Senior Management" is defined as all executives except the Group Chairman, holding key strategy roles and reporting to the Board/CEO.

Adequate wages

Reference: page 220 (Own workforce).

0% of employees in Italy or Brazil receive wages below applicable benchmarks — i.e., all Group employees receive wages compliant with national collective agreements and regulatory minimums in their country of employment. This is cross-referenced to disclosure S1-8 "Collective bargaining coverage," under which 100% of employees are covered by applicable CBAs setting minimum wage terms.

Persons with disabilities

Reference: page 220 (Own workforce).

Italian reporting follows Law 68/1999 (employment obligation categories) and Legislative Decree 62/2024's definition of disability; Brazilian reporting follows federal law's permanent-impairment definition with formal medical/CID classification as "PCD" (Pessoa com Deficiência).

Training and skills development metrics

Reference: page 220-221 (Own workforce), TIM Group.

Performance-review participation rose sharply as review processes were extended across the Group. Training hours fell 13% YoY, reflecting a 2025 shift toward face-to-face, higher-specialization courses with a greater focus on formal certifications rather than volume of hours.

Health and safety metrics

Reference: page 221-222 (Own workforce), TIM Group. Note: datapoints 88 a-c and RA80 are subject to phase-in for non-employees.

No fatalities recorded for a second consecutive year. The injury rate rose YoY, attributed to a higher incidence of longer-prognosis (20+ day) events, including some occurring during agile/remote work.

Work-life balance metrics

Reference: page 222-223 (Own workforce), TIM Group.

100% of employees are entitled to family-related leave. In 2025, 3,627 employees (13.86%) took family-related leave, up from 3,103 (11.57%) in 2024 — a 16.9% increase. Uptake is higher among women (17.37%) than men (10.40%), though both rose YoY, reflecting broader use of work-life-balance provisions such as the #BParent Plan and Family Audit certification described under S1-4.

Compensation metrics – pay gap and remuneration ratio

Reference: page 223 (Own workforce).

Unadjusted gender pay gap: Group level 24.49% (2024: 24.41%); Domestic level 19.92% (2024: 19.8%); excluding customer-care roles (~80% female, lower grade concentration), Group gap narrows to 18.47% and Domestic to 14.26%. TIM S.A. reports a separate like-for-like (same-role) pay gap of 1.8%, not directly comparable to the ESRS aggregate measure.

Pay ratio: highest-to-median total remuneration ratio was 90.20 in 2025, improved from 92.86 in 2024 (fixed plus target variable pay; non-monetary benefits excluded as residual).

Incidents, complaints and severe human rights impacts

Reference: page 224 (Own workforce).

Domestic (2025): 45 human-rights-related whistleblowing reports received (2024: 43), of which 43 related to discrimination/harassment; outcomes: 1 substantiated, 11 not substantiated, 31 under investigation; the remaining 2 reports (non-discrimination human-rights matters) still being explored.

Brazil: 12 human-rights reports (9 alleged discrimination/harassment: 5 unfounded, 4 inconclusive; corrective/awareness measures taken regardless); of 3 non-discrimination reports, 1 well-founded and 1 partially well-founded, with corrective action taken.

Information security: ~500 reports received; 39 classified as incidents. No employee-data breaches requiring notification in 2025. No serious human-rights incidents (forced labor, child labor, trafficking) were recorded across workforce, value-chain workers, communities or customers, consistent with 2024. No substantiated report resulted in external fines or sanctions.

Policies related to value chain workers

Reference: page 226 (Workers in the value chain).

The double materiality analysis identified a negative impact (IRO 15) and a risk (IRO 38) related to "Workers in the value chain," monitored through the Human Rights Policy, the Purchases of Products and Services Policy, and the Health and Safety Policy.

TIM S.A. additionally applies a "Relations with Suppliers" policy (human rights/dignified working conditions), a Social Responsibility Policy, and an Occupational Health and Safety policy extending to supplier workers in Brazil.

Value-chain workers considered material include: upstream network/ICT/device suppliers and on-site technical-assistance/consultancy contractors; downstream logistics, distribution and installation partners; and joint-venture workers (e.g., TIMFin S.p.A., National Strategic Hub).

Actions on material impacts on value chain workers

Reference: page 226-227 (Workers in the value chain).

Secure employment: supply contracts prohibit forced/child labor and require compliance with working-hours, pay and non-discrimination law; verified via qualification, periodic evaluation and on-site audits (mitigates IRO 38).

Health and safety: supplier qualification includes H&S compliance checks (ISO 45001 for higher-risk profiles); TIM S.A. risk management applies Brazilian Regulatory Standard NR-01 (mitigates IRO 15; TIM S.A. spend €17.7k OpEx).

Ethical/social qualification: ~35% of 299 qualified Domestic suppliers received ESG assessment in 2025; Brazil evaluated 354 suppliers (251 approved, 103 excluded). 4 JAC-framework audits conducted on at-risk suppliers, covering child/forced labor, freedom of association, discrimination, wages, H&S and environment.

Data confidentiality: contractual technical/organizational security requirements for suppliers processing personal data, monitored via the Group's SCIGR. Total identifiable spend: Domestic BU €60k OpEx; TIM S.A. €63.7k OpEx (S2-4 aggregate, plus €46k OpEx supplier qualification).

Targets related to value chain workers

Reference: page 229 (Workers in the value chain).

TIM monitors: (1) health and safety — supplier compliance with company H&S procedures via qualification processes, audits and periodic checks, aimed at accident prevention and risk reduction for supply-chain workers; and (2) human rights — the number and type of reports of potential violations involving value-chain workers, received through Code of Ethics/company-procedure channels, to enable prompt corrective action. No quantified numeric target level is disclosed for these KPIs in the 2025 statement.

Policies related to affected communities

Reference: page 230 (Reference communities and territories).

The double materiality analysis identified two material IROs (19 and 32) related to "Communities and reference territories," governed by the Code of Ethics and Conduct and the Human Rights Policy. In Italy, TIM's "Stakeholder Engagement Guidelines" define community-dialogue principles; in Brazil, TIM S.A.'s "Engagement Policy" governs local-stakeholder relations, and its Social Responsibility Policy provides for prior consultation of indigenous, traditional and Quilombola communities before investments affecting their territories. No significant impacts on indigenous peoples were identified in the Italian context.

Actions on material impacts on affected communities

Reference: page 230-234 (Affected communities).

Digital education: "Mind The Web" (IDMO/Ministry of Education) reached 46,000 students and 750+ teachers across ~350 schools, plus 1,000 students in Italian schools abroad; TIMVISION Agenda 2030 children's content (8% audience share).

Territory development: Brazil rural-connectivity project covered 26.2m hectares (4G) and 53.1m hectares (NB-IoT) toward a 32m-hectare 2026 target, benefiting 2.6m+ rural residents.

Inclusion: Women Plus, "Equality Can't Wait" podcast (8 episodes, ~8,000 combined views), Pride sponsorship, Accessibility Days participation.

TIM Foundation: ~€1.5m allocated to Research/Inclusion/Health calls in 2025, funding 6 national entities (24-month projects); continued restoration of the Mausoleum of Augustus.

TIM Institute (Brazil): 700,000+ people supported across 500 cities since 2013; Academic Working Capital has backed 240 projects/128 startups since 2015.

Contributes to positive impact IRO 19 and opportunity IRO 32. Total spend: Domestic BU €994k OpEx/€63k CapEx; TIM S.A. €92.5k OpEx.

Targets related to affected communities

Reference: page 235 (Affected communities).

TIM monitors: the number of initiatives carried out and beneficiaries reached (capacity to reach reference communities); territorial extension/coverage of initiatives (dissemination and accessibility); and participation levels and recipient satisfaction via feedback tools and questionnaires (perceived effectiveness). No quantified numeric target level is disclosed for these KPIs in the 2025 statement, beyond the TIM S.A. rural-connectivity coverage target referenced under S3-4 (32 million hectares by 2026).

Policies related to consumers and end-users

Reference: page 237 (Consumers and end-users).

The double materiality analysis identified fourteen material IROs (1, 3, 6, 10, 11, 12, 16, 19, 25, 26, 27, 28, 33 and 34) related to "Consumers and End Users," addressed within the Human Rights Policy, Code of Ethics and Conduct, Information Security Policy, Personal Data Protection Framework, Business Continuity Policy, and the TIM Service Charter (AGCOM Resolution 179/03/CSP).

TIM S.A. additionally applies a Brazil-specific Privacy Policy (LGPD-aligned, prohibiting marketing to minors) and a Cybersecurity Policy covering network/service security and incident management.

Engaging with consumers and end-users

Reference: page 237 (Consumers and end-users).

Customer experience listening: over 3,000,000 pieces of customer feedback collected in 2025, covering the full customer journey; ~3,000 customers surveyed specifically for the DMA.

Metrics: Customer Satisfaction Index (CSI) and Net Promoter Score (NPS); the Detractor rate improved to 15.74% in 2025, from 19.28% in 2024.

Indirect engagement: ongoing dialogue with consumer associations (including on Alternative Dispute Resolution mechanisms and vulnerable-customer needs); TIM S.A. operates a TIM User Council and engages Procons, Consumidor.gov.br and Anatel in Brazil. Oversight sits with the Chief Enterprise and Chief Consumer offices, supported by Data Analytics/AI/Customer Insight, under Sustainability Committee governance.

Remediation channels for consumers and end-users

Reference: page 237-239 (Consumers and end-users).

Voice/digital channels: Customer Service 187 (landline)/119 (mobile)/191 (business); MyTIM app with "Angie" AI virtual assistant; AI-supported social-media care.

Joint Conciliation (with consumer associations): an Alternative Dispute Resolution mechanism handling ~7,500 cases/year capacity; in 2025, 9,058 cases handled (+21% YoY), with a 97% positive-agreement rate for customers.

Enterprise channels: Sinfonia technical assistance, Telsy Security/SOC toll-free line, TuConTI ticketing portal.

Whistleblowing extends to external customers/end-users, and a dedicated Abuse Desk handles cyber-abuse reports. These channels address material IROs including data privacy/cybersecurity vulnerabilities (IRO 1) and service-continuity disruption (IRO 16, 27).

Actions on material impacts on consumers and end-users

Reference: page 240-246 (Consumers and end-users).

Smart City/Enterprise solutions: "TIM Urban Genius" activated 23 of 68 Public Administration digital-transition projects in 2025 (air quality, traffic, safety monitoring for municipalities).

Accessibility: dedicated accessibility phones; TIMVISION Listen (audio description for blind/visually impaired users); Brazil's WCAG/W3C-aligned online channels including a Libras Center for sign-language video-call support.

Data protection/cybersecurity: continuous monitoring of security incidents and breach notification processes (mitigating IRO 1, 26); business-continuity testing against service disruption (mitigating IRO 16, 27).

Digital education: conscious-use and online-safety training initiatives targeting vulnerable users (supporting positive impacts IRO 6, 19, and opportunities IRO 3, 10, 11).

Operational KPIs tracked include customer-satisfaction levels and the number of security incidents potentially affecting customers.

Targets related to consumers and end-users

Reference: page 245-246 (Consumers and end-users).

TIM's prior digital-growth targets are being updated with the new Business Plan; new targets will be formalized during 2026. In the interim, TIM monitors: security/data-protection indicators (relevant security events including breaches, incident-handling times, cybersecurity-safeguard testing); service reliability/continuity indicators (technical performance, recovery times, business-continuity-plan testing); customer-experience quality indicators (NPS, CSI, complaint volumes/resolution times, joint conciliations, regulatory sanctions); and accessibility/conscious-use indicators (digital-education participation for vulnerable users). Results against prior targets are reported under ESRS 2 SBM-1.

Business conduct policies and corporate culture

Reference: page 247-248 (Business conduct).

The double materiality analysis identified six material IROs (2, 4, 8, 14, 29, 34) related to business conduct, overseen through the Code of Ethics and Conduct, the 231 Organizational Model, the Anti-Corruption Policy, the Tax Strategy, the Remuneration Policy Report, the Purchasing and Services Policy, and the Artificial Intelligence Guidelines, all approved by the Board of Directors.

Anti-corruption: ISO 37001-certified Anti-Corruption Management System (AMS); Board approved 231 Model version 7.5 in 2025, incorporating updates on cybersecurity/computer-crime law, excise duties, and irregular-foreign-national employment law.

AI governance: a Steering Committee oversees responsible AI adoption against the Group's AI Guidelines, assessing reputational, regulatory and operational risk across customer, network and central functions.

Tax: a Tax Control Framework operates under the Revenue Agency's Cooperative Compliance regime (since 2017). 2025 spend on G1-1 actions: Domestic BU €285.9k OpEx; TIM S.A. €340k OpEx/€96.2k CapEx.

Management of relationships with suppliers

Reference: page 248-251 (Business conduct).

2025 supply chain scale (TIM Group): 2,586 active Tier-1 suppliers (Italy 1,937; Brazil 649); 123,635 purchase deeds; €5.318bn value of purchases; 267 new suppliers onboarded.

ESG qualification (Domestic): suppliers with orders ≥€250k in high-risk regions (Asia, Central/South America, North Africa, Eastern Europe) or ≥€500k generally must pass a 30+-question ESG questionnaire (≥40% positive-response threshold; certifications include SA8000, ISO 45001/37001/30415). ~300 suppliers qualified in 2025, >35% ESG-assessed; 100% of new qualified suppliers signed the Code of Ethics.

Monitoring: 768 suppliers received second-party audits (Domestic); 151 JAC audits identified 794 non-conformities; suppliers with detected negative impacts rose to 344 (from 137 in 2024), reflecting expanded control scope. Open-es platform: 1,400+ TIM suppliers profiled (+8% YoY). 2025 spend: Domestic BU €203k OpEx.

Prevention and detection of corruption and bribery

Reference: page 251-253 (Business conduct).

TIM S.p.A.'s Anti-Corruption Management System (AMS) has been ISO 37001-certified since 2019 (reconfirmed through 2028); also certified at TIM S.A. (2021), Olivetti (2022), TI Trust Technologies (2022), Telecontact Center (2022) and Telecom Italia Sparkle (2023).

Risk-based approach identifies "Personnel in Significant Positions" and "Significant Third Parties" across high-risk areas (procurement, investments, sales, HR, finance/tax, gifts/sponsorships, licensing). An IT system supports Third-Party risk assessment for indirect-network suppliers/partners.

Training: 100% of at-risk functions covered; 31,000+ training hours on governance/ethics/anti-corruption delivered in 2025; 117 business partners used a dedicated integrity video since 2023. Brazil: 3,967 employees trained on integrity/anti-corruption; 100% of governance-body members briefed; 3 risk-based audit streams completed with no corruption findings.

Incidents of corruption or bribery

Reference: page 253-254 (Business conduct).

No cases of active or passive corruption were ascertained in 2025 for TIM S.p.A. or Group companies within the reporting scope, consistent with 2024. Monitoring continued during the year of a proceeding related to an alleged case of corruption between private individuals, involving a former TIM executive, which emerged in 2024.

TIM S.A.: no convictions or financial penalties were imposed for active or passive corruption violations in 2025.

Payment practices

Reference: page 253-254 (Business conduct).

Standard contractual payment terms generally do not exceed 120 days from invoice date (Domestic), conventionally fixed to month-end, with exceptions per framework agreements. Reverse-factoring programs are offered to suppliers on a voluntary basis.

TIM S.p.A. (2025): 100% of payments made within standard terms; average payment days — 113 (subject to financial agreements), 100 (not subject to agreements), 103 days overall average. 6 pending supplier disputes over alleged non-payment, totalling €13,206,864.

TIM S.A.: average payment days of 42, with no payment disputes of this nature.